ASG Law

Tag: Accessory Liability

  • Obstruction of Justice: When Aiding a Principal Overshadows Accessory Liability in Philippine Law

    In Padiernos v. People, the Supreme Court clarified the distinction between accessory liability and obstruction of justice. The Court ruled that individuals who actively conceal or suppress evidence to frustrate the successful prosecution of criminal offenders should be charged with obstruction of justice rather than as accessories to the underlying crime. This decision underscores that the specific acts performed by an individual, not the label attached to their involvement, determine their criminal liability under the law. This ruling ensures that actions taken to impede justice are appropriately penalized.

    Truck Heist or Justice Obstructed? Unraveling Accessory Liability in Illegal Logging

    This case revolves around events following the confiscation of a truck loaded with illegally obtained lumber. The central question is whether the actions of Jackson Padiernos, Jackie Roxas, and Rolando Mesina, who took the truck away from authorities, constitute accessory liability to the crime of illegal possession of lumber, or the distinct offense of obstruction of justice.

    The case originated when authorities seized a truck containing undocumented lumber. Following the seizure, Santiago Castillo, the truck’s owner, along with Padiernos, Roxas, and Mesina, arrived at the scene. Castillo convinced Mesina to drive the truck, assuring them that any issues regarding the truck’s legality had been resolved. As Mesina drove, the other individuals boarded the truck, and sped away, leading to a chase and eventual apprehension by the Philippine Army. Initially charged as accessories to the crime of illegal possession of lumber, the Regional Trial Court (RTC) found Padiernos, Mesina, and Roxas guilty. The Court of Appeals (CA) affirmed this decision, emphasizing that the truck was an instrument in the commission of the crime, making its removal an act of accessory liability.

    However, the Supreme Court disagreed with the lower courts’ assessment. The Court emphasized a crucial principle: the nature of the offense is determined by the factual allegations in the Information (the charging document), not merely the technical name assigned to the crime. In this instance, the Information stated that the accused “did then and there unlawfully, feloniously and willfully take and carry away the aforementioned ten wheeler truck with Plate No. TFZ-747 so it could not be used as evidence and avoid confiscation and forfeiture in favor of the government as tool or instrument of the crime.”

    To fully appreciate the legal reasoning behind the Supreme Court’s decision, it is helpful to understand the definition of accessories under Article 19 of the Revised Penal Code (RPC). This provision defines accessories as individuals who, with knowledge of the commission of the crime and without having participated as principals or accomplices, take part subsequent to its commission by concealing or destroying the body of the crime, its effects, or instruments, in order to prevent its discovery. The key element here is preventing the discovery of the crime. In this case, the illegal possession of lumber had already been discovered when the truck was confiscated; therefore, the petitioners’ actions did not meet the definition of accessory liability.

    Instead, the Supreme Court found that the petitioners’ actions constituted obstruction of justice, as defined under Section 1(b) of Presidential Decree (P.D.) No. 1829. This decree penalizes acts that obstruct or frustrate the apprehension and prosecution of criminal offenders. Specifically, Section 1(b) addresses individuals who knowingly or willfully obstruct, impede, frustrate, or delay the apprehension of suspects and the investigation and prosecution of criminal cases by “altering, destroying, suppressing or concealing any paper, record, document, or object, with intent to impair its verity, authenticity, legibility, availability, or admissibility as evidence in any investigation of or official proceedings in criminal cases, or to be used in the investigation of, or official proceedings in criminal cases.”

    The Supreme Court reasoned that the truck served as material evidence in the criminal investigation for violation of P.D. 705. By taking the truck, the petitioners intentionally suppressed evidence to impair its availability and prevent its use in the criminal investigation. The Court considered the petitioners’ knowledge of the truck’s involvement in the illegal activity, as well as the evidence of their conspiracy. Given these factors, the court found that the petitioners actions fell squarely within the definition of obstruction of justice.

    This case highlights the importance of aligning the factual allegations in the Information with the appropriate legal definition of the crime. The Court found that the lower courts erred in convicting the accused as accessories because the crime of illegal possession had already been discovered when they committed the act. The Supreme Court therefore reclassified the crime to Obstruction of Justice and meted out appropriate penalties.

    FAQs

    What was the central issue in this case? The central issue was whether the petitioners were liable as accessories to the crime of illegal possession of lumber, or for obstruction of justice, after they took away a truck that had been confiscated for carrying illegal lumber.
    What is the definition of an accessory under Article 19 of the Revised Penal Code? An accessory is someone who, with knowledge of the commission of a crime and without participating as a principal or accomplice, takes part after the crime’s commission by concealing or destroying evidence to prevent its discovery.
    What is obstruction of justice under P.D. 1829? Obstruction of justice, under P.D. 1829, involves actions that knowingly and willfully obstruct, impede, frustrate, or delay the apprehension of suspects or the investigation and prosecution of criminal cases, including suppressing or concealing evidence.
    Why were the petitioners not considered accessories in this case? The petitioners were not considered accessories because the crime of illegal possession of lumber had already been discovered when they took the truck; thus, their actions did not prevent the crime’s discovery.
    What evidence led the court to conclude that the petitioners were guilty of obstruction of justice? The court considered the petitioners’ knowledge of the truck’s involvement in illegal activities, their deliberate act of taking the truck, and their intent to prevent its use as evidence in the criminal investigation.
    What does the Information in a criminal case determine? The Information, the charging document, determines the nature of the offense, based on the factual allegations, rather than the technical name or label assigned to the crime.
    What penalty did the petitioners receive for obstruction of justice? The petitioners were sentenced to suffer the penalty of prision correccional for 4 years, 9 months, and 11 days to 5 years, 4 months, and 20 days, in accordance with Section 1(b) of P.D. 1829.
    What was the role of the truck in the illegal possession of lumber case? The truck served as material evidence, linking individuals to the illegal possession and transportation of lumber, and was considered indispensable for the criminal investigation.

    This case underscores the principle that criminal liability is determined by the specific acts committed and their alignment with legal definitions. It emphasizes the importance of accurately charging individuals based on their actions, ensuring appropriate penalties are applied to those who obstruct the course of justice.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Jackson Padiernos v. People, G.R. No. 181111, August 17, 2015

  • What Constitutes ‘Inducement’ to Commit a Crime? Philippine Supreme Court Clarifies Criminal Liability

    When Words are Not Enough: Understanding Criminal Inducement in Philippine Law

    In Philippine criminal law, not all words carry the weight of criminal inducement. A seemingly strong statement might not be enough to make someone a principal by inducement in a crime. This case clarifies that mere words, without a clear intent to instigate a specific crime and a causal link to its commission, fall short of legally defined inducement. It underscores the high bar for proving inducement and highlights the importance of direct evidence and intent in establishing criminal liability.

    G.R. No. 133527-28, December 13, 1999

    INTRODUCTION

    Imagine overhearing a heated argument where someone frustratedly shouts, “Just get rid of them!” and later, the subject of their anger is found harmed. Does this outburst automatically make the speaker criminally responsible for the harm? Philippine law, as illustrated in the Supreme Court case of People of the Philippines v. Jeanette Yanson-Dumancas, provides a nuanced answer, particularly when determining criminal liability based on ‘inducement’. This case, stemming from a gruesome kidnapping for ransom and murder, delves deep into what constitutes ‘inducement’ and the necessary elements to hold someone accountable as a principal in a crime.

    In 1992, Danilo Lumangyao and Rufino Gargar Jr. allegedly swindled Jeanette Yanson-Dumancas. Driven by a desire to recover her losses, Jeanette, along with several police officers and civilians, were accused of orchestrating the kidnapping and subsequent murder of Lumangyao and Gargar. The prosecution argued that Jeanette, as a principal by induction, instigated the crimes through her commands. The Supreme Court meticulously examined the evidence to determine if her actions legally constituted criminal inducement.

    LEGAL CONTEXT: PRINCIPALS BY INDUCTION AND ACCESSORIES

    Philippine criminal law, rooted in the Revised Penal Code (RPC), carefully delineates different degrees of criminal participation. Article 17 of the RPC defines principals, including those who “directly force or induce others to commit” a crime (principal by induction). This is distinct from principals by direct participation, who directly execute the criminal act, and accomplices, who cooperate in the execution by previous or simultaneous acts.

    Crucially, to be considered a principal by induction, mere suggestion or influence is insufficient. The law requires a direct and forceful instigation. As the Supreme Court referenced in this case, in U.S. vs. Indanan, inducement must stem from a “most positive resolution and the most persistent effort to secure the commission of the crime, together with the presentation to the person induced of the very strongest kind of temptation to commit the crime.” This high threshold ensures that casual remarks or ambiguous statements are not misconstrued as criminal instigation.

    Furthermore, the element of intent is paramount. The inducement must be made with the specific intention of procuring the commission of the crime. A statement made in anger or frustration, without a clear, premeditated intent to cause a specific illegal act, generally does not meet the legal definition of inducement. The Supreme Court also emphasized that the act of inducement must precede the commission of the crime itself. An order given after the crime has already begun cannot be considered the ‘inducement’ that led to its initiation.

    Separately, Article 19 of the RPC defines accessories. These are individuals who, with knowledge of the crime’s commission and without prior participation, take part *after* its execution. Acts of accessories include profiting from the crime, concealing the body or evidence, or harboring the principals. Accessory liability carries a lesser penalty compared to principals and accomplices, reflecting their less direct role in the crime itself.

    CASE BREAKDOWN: WORDS, ACTIONS, AND CRIMINAL INTENT

    The case unfolded with the abduction of Rufino Gargar Jr. and Danilo Lumangyao. Driven by the swindling incident, a group including police officers and civilian agents, acting under the influence of Jeanette Yanson-Dumancas and Police Colonel Nicolas Torres, apprehended the victims. The victims were moved between motels, interrogated about the money, and ultimately murdered. Cesar Pecha was later involved in burying the bodies to conceal the crime.

    The prosecution’s case against Jeanette hinged on her alleged ‘commands’ to Dominador Geroche, one of the perpetrators, to “take care of the two.” The trial court interpreted these words as inducement, leading to her conviction as a principal. However, the Supreme Court disagreed, meticulously dissecting the nature of these statements and the context in which they were uttered.

    The Supreme Court highlighted the testimony of prosecution witness Moises Grandeza, who, during cross-examination, revealed that Jeanette had also instructed Geroche to bring the victims to the police and file proper cases. This crucial piece of testimony cast significant doubt on whether Jeanette’s “take care of the two” remark was indeed a command to kill, or rather an ambiguous statement open to interpretation. The Court stated, “By no stretch of the imagination may these so-called ‘commands’, standing alone, be considered as constituting irresistible force or causing uncontrollable fear.”

    Furthermore, the Court noted that the plan to abduct the victims predated any alleged inducement by Jeanette. The abduction, a core element of kidnapping, was already underway when Jeanette supposedly gave the command. Therefore, her words could not be considered the determining cause of the kidnapping itself. The Supreme Court quoted U.S. vs. Indanan, emphasizing that “a chance word spoken without reflection, a wrong appreciation of a situation, an ironical phrase, a thoughtless act, may give birth to a thought of, or even a resolution to crime…without the one who spoke the word…having any expectation that his suggestion would be followed or any real intention that it produce the result.”

    Ultimately, the Supreme Court acquitted Jeanette Yanson-Dumancas and Police Inspector Adonis Abeto, finding the evidence insufficient to prove inducement or conspiracy beyond reasonable doubt for Abeto. However, other accused, including Mario Lamis, Dominador Geroche, Jaime Gargallano, Rolando R. Fernandez, Edwin Divinagracia, and Teody Delgado, were convicted as principals by direct participation. Cesar Pecha was convicted as an accessory for concealing the bodies. Police Colonel Nicolas Torres’ case was dismissed due to his death during the appeal process.

    PRACTICAL IMPLICATIONS: THE WEIGHT OF WORDS AND INTENT

    This case serves as a critical reminder about the burden of proof in criminal cases, especially when dealing with complex concepts like inducement and conspiracy. It underscores that mere presence, association, or even ambiguous words are not enough to establish criminal liability, particularly for principals by induction. The prosecution must present clear and convincing evidence demonstrating:

    • Specific Intent: The accused must have had a clear and deliberate intention to induce the commission of a specific crime.
    • Direct Inducement: The inducement must be direct, forceful, and the determining cause of the crime. Vague suggestions or ambiguous remarks are insufficient.
    • Causal Link: A clear causal link must exist between the inducement and the commission of the crime. The induced act must be a direct consequence of the inducement.
    • Precedence: The act of inducement must precede the commencement of the crime.

    For law enforcement and prosecutors, this ruling emphasizes the need for thorough investigation and the gathering of concrete evidence, beyond circumstantial inferences, to prove inducement. For individuals, it offers a degree of protection against being held criminally liable for unintended interpretations of their words, spoken in moments of stress or frustration, provided there was no genuine intent to instigate a specific crime.

    KEY LESSONS

    • Inducement Requires Intent: To be a principal by inducement, you must intentionally and directly cause another person to commit a crime.
    • Words Must Be Clear and Direct: Ambiguous statements or suggestions are generally insufficient to establish inducement.
    • Causation is Key: The inducement must be the direct and determining cause of the criminal act.
    • Burden of Proof is High: Proving inducement beyond reasonable doubt requires strong, direct evidence of intent and causation.
    • Accessory Liability is Distinct: Helping to conceal a crime after its commission carries a lesser degree of liability than being a principal.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q: What is the difference between a principal by induction and a principal by direct participation?

    A: A principal by direct participation directly commits the criminal act, for example, pulling the trigger in a murder. A principal by induction, on the other hand, does not directly commit the act but instigates or compels another person to commit it through forceful commands or inducements.

    Q: What kind of evidence is needed to prove inducement in court?

    A: Strong evidence is required, such as direct testimony of witnesses who heard the explicit command or inducement, written communications, or other forms of proof that clearly demonstrate the inducer’s intent and direct causation of the crime. Circumstantial evidence alone is often insufficient.

    Q: Can I be held liable for a crime if someone misinterprets my words and commits a crime based on that misinterpretation?

    A: Not necessarily. As this case shows, Philippine law requires a clear intent to induce a specific crime. If your words are ambiguous or open to misinterpretation, and you did not have the specific intent to instigate the crime, you are less likely to be held liable as a principal by induction.

    Q: What is the penalty for being an accessory to a crime compared to being a principal?

    A: Accessories generally face lighter penalties than principals or accomplices. The penalty for an accessory is typically lower by one or two degrees than that prescribed for the principal crime, reflecting their less direct involvement.

    Q: If I am present at the scene of a crime, does that automatically make me a conspirator?

    A: No. Mere presence at the scene of a crime is not sufficient to prove conspiracy. Conspiracy requires an agreement and unity of purpose among the conspirators to commit the crime. The prosecution must prove that you actively participated in the planning or execution of the crime, not just that you were present.

    Q: What should I do if I am accused of being a principal by induction in a crime?

    A: Seek legal counsel immediately. A lawyer specializing in criminal law can assess the evidence against you, advise you on your rights, and build a strong defense. It’s crucial to understand the nuances of inducement and conspiracy in Philippine law and to present evidence that challenges the prosecution’s claims of intent and causation.

    ASG Law specializes in Criminal Litigation. Contact us or email hello@asglawpartners.com to schedule a consultation.

  • Circumstantial Evidence and Criminal Liability: Understanding Conspiracy and Accessory Roles in Kidnapping

    When Circumstantial Evidence Isn’t Enough: Distinguishing Principals from Accessories in Kidnapping Cases

    TLDR: This case clarifies how circumstantial evidence is evaluated in kidnapping cases, particularly in determining if someone is a principal or merely an accessory. It emphasizes that while circumstantial evidence can prove conspiracy, it must eliminate reasonable doubt of innocence. The Supreme Court downgraded the conviction of one accused from principal to accessory, highlighting the importance of proving direct participation beyond profiting from the crime’s effects.

    G.R. No. 115351, March 27, 1998

    INTRODUCTION

    Imagine being wrongly accused of a serious crime, where the evidence against you is not direct but based on assumptions and interpretations of your actions. This is the precarious situation Rodrigo Legarto faced in People v. Maluenda. This Supreme Court decision serves as a crucial reminder of the burden of proof in criminal cases, particularly when relying on circumstantial evidence to establish guilt in complex crimes like kidnapping. While circumstantial evidence can be powerful, this case demonstrates its limitations and the critical distinction between being a principal in a crime and merely an accessory after the fact.

    The case revolves around the kidnapping of Engr. Miguel Resus, where Raul Mondaga was clearly the mastermind. The central legal question became whether Rodrigo Legarto and Daniel Maluenda were principals in the kidnapping, as the trial court found, or if their roles were different, requiring a reassessment of their criminal liability based on the evidence presented.

    LEGAL CONTEXT: PRINCIPALS, ACCESSORIES, AND CIRCUMSTANTIAL EVIDENCE

    Philippine criminal law, as defined by the Revised Penal Code, categorizes individuals involved in a crime into principals, accomplices, and accessories. Principals are directly involved in the execution of the crime, while accessories participate after the crime has been committed. Understanding these distinctions is crucial because they determine the degree of criminal liability and the corresponding penalties.

    Article 17 of the Revised Penal Code defines principals, including “Those who cooperate in the commission of the offense by another act without which it would not have been accomplished.” This is known as principal by indispensable cooperation. On the other hand, Article 19 defines accessories as those who, having knowledge of the crime’s commission, take part subsequent to its commission in specific ways, such as “profiting themselves or assisting the offender to profit by the effects of the crime.”

    In many criminal cases, direct evidence of guilt may be scarce. Philippine courts, therefore, allow convictions based on circumstantial evidence. Section 4, Rule 133 of the Rules of Court dictates the conditions for circumstantial evidence to be sufficient for conviction:

    “SEC. 4. Circumstantial evidence, when sufficient.—Circumstantial evidence is sufficient for conviction if: (a) There is more than one circumstance; (b) The facts from which the inferences are derived are proven; and (c) The combination of all circumstances is such as to produce a conviction beyond reasonable doubt.”

    Crucially, the Supreme Court has consistently held that for circumstantial evidence to warrant conviction, it must exclude every reasonable hypothesis except that of guilt. This means the circumstances must not only be consistent with guilt but also inconsistent with innocence.

    CASE BREAKDOWN: FROM PRINCIPAL TO ACCESSORY

    The story unfolds with Engr. Miguel Resus and his wife arriving at their clinic in Surigao del Sur, only to be confronted by three men: Mondaga, Maluenda, and “Alex.” Mondaga, posing as an NPA commander, initially demanded money and medicines, eventually escalating to the kidnapping of Engr. Resus for ransom. The prosecution painted a picture of conspiracy, alleging that Legarto and Maluenda were integral to this scheme.

    The Trial Court’s Decision: The Regional Trial Court (RTC) convicted Mondaga, Maluenda, and Legarto as principals of kidnapping for ransom. The RTC relied heavily on circumstantial evidence, pointing to Legarto’s acquaintance with Mondaga, his transportation of Maluenda and “Alex” before the kidnapping, his delivery of ransom notes and money, and his use of ransom money to pay for his motorcycle.

    The Appeal to the Supreme Court: Legarto and Maluenda appealed their conviction, arguing that the evidence was insufficient to prove their direct participation as principals. Mondaga initially appealed but later withdrew his appeal.

    The Supreme Court meticulously reviewed the circumstantial evidence against Legarto. The Court noted several key points:

    • Acquaintance is not proof of conspiracy: While Legarto knew Mondaga, mere association does not equate to criminal conspiracy.
    • Transporting suspects is speculative: The evidence that Legarto transported Maluenda and “Alex” was based on inference, not direct observation. Engr. Resus only saw Legarto returning, not transporting the other accused.
    • Motorcycle requisition was not specifically for Legarto’s: Mondaga initially asked for the victim’s motorcycle; Legarto’s was requested only after the victim’s was deemed unusable.
    • Ransom delivery and benefit do not automatically imply principal role: Legarto claimed he delivered the ransom out of loyalty to the victim and that the money he kept was payment for his motorcycle, taken as part of the ransom demand.
    • Failure to testify in a separate case is irrelevant: Legarto’s reluctance to pursue a carnapping case against Mondaga involving his motorcycle does not prove his participation in the kidnapping.

    The Supreme Court emphasized, “In this case, the totality of the pieces of circumstantial evidence being imputed to Legarto does not foreclose the possibility that he took no part in the criminal enterprise and does not, therefore, overcome his constitutional right to be presumed innocent.”

    However, the Court also found that Legarto was not entirely blameless. He profited from the crime by using ransom money to pay off his motorcycle loan and subsequently reclaimed the motorcycle. The Court concluded:

    “Legarto may not have had a direct hand in the kidnapping, but he received part of the ransom and used it to pay off his arrears in his motorcycle loan. Thus, having knowledge of the kidnapping for ransom and without having directly participated therein, he took part in the crime subsequent to its commission by profiting from its effects.”

    The Supreme Court’s Ruling: The Supreme Court affirmed Maluenda’s conviction as a principal in kidnapping, finding sufficient evidence of his direct participation. However, it modified Legarto’s conviction, downgrading it to accessory to kidnapping for ransom. Legarto was sentenced to a lighter indeterminate prison term and ordered to return the P36,000 he used from the ransom money.

    PRACTICAL IMPLICATIONS: LESSONS FOR CRIMINAL DEFENSE AND PROSECUTION

    People v. Maluenda provides several critical takeaways for both legal practitioners and individuals who might find themselves entangled in criminal proceedings:

    • Burden of Proof Remains with the Prosecution: The prosecution must prove guilt beyond a reasonable doubt. In cases relying on circumstantial evidence, this burden is even higher. Assumptions and inferences are not enough; the circumstances must logically and unequivocally point to guilt and exclude every reasonable hypothesis of innocence.
    • Distinguishing Roles is Crucial: Criminal liability is not monolithic. The law differentiates between principals, accomplices, and accessories. Accurately defining each person’s role in a crime is essential for just sentencing. Being present or even benefiting from a crime does not automatically make one a principal.
    • Circumstantial Evidence Must Be Scrutinized: While valuable, circumstantial evidence is not foolproof. Courts must meticulously examine each piece of circumstantial evidence, ensuring that the facts are proven and the inferences drawn are logical and compelling. Speculation and presumption have no place in establishing criminal guilt.
    • Accessory Liability is a Real Possibility: Even if not directly involved in the planning or execution of a crime, individuals can still be held criminally liable as accessories if they profit from the crime or assist others in doing so, with knowledge of the crime’s commission.

    Key Lessons

    • For Individuals: Be cautious about getting involved in situations where you might indirectly benefit from or assist in a crime, even if you weren’t part of the initial plan. Knowledge and subsequent actions can lead to accessory liability.
    • For Legal Professionals: When prosecuting based on circumstantial evidence, ensure every circumstance is firmly established and leads to an inescapable conclusion of guilt. For the defense, meticulously dissect the prosecution’s circumstantial evidence to identify alternative hypotheses and reasonable doubts.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q: What is circumstantial evidence?

    A: Circumstantial evidence is indirect evidence that implies something is true but doesn’t prove it directly. Think of it like footprints in the snow – they suggest someone walked there, but you didn’t see them walking.

    Q: How is circumstantial evidence used in court?

    A: Philippine courts allow convictions based on circumstantial evidence if there is more than one circumstance, the facts are proven, and the combination of circumstances leads to a conviction beyond a reasonable doubt.

    Q: What is the difference between a principal and an accessory in a crime?

    A: A principal is directly involved in committing the crime, either by direct participation, inducement, or indispensable cooperation. An accessory’s involvement comes *after* the crime, such as helping the principal profit from the crime or concealing evidence.

    Q: Can someone be convicted of kidnapping based only on circumstantial evidence?

    A: Yes, but the circumstantial evidence must be strong enough to prove guilt beyond a reasonable doubt. It must exclude all reasonable hypotheses of innocence.

    Q: What is the penalty for being an accessory to kidnapping compared to being a principal?

    A: Accessories generally face a lighter penalty. In kidnapping cases, the penalty for an accessory is two degrees lower than that for principals.

    Q: If I unknowingly benefit from a crime, am I automatically an accessory?

    A: Not necessarily. Accessory liability requires *knowledge* of the crime’s commission. If you genuinely didn’t know the money or benefit you received came from a crime, you might not be liable as an accessory. However, the specifics of each situation are crucial and legal advice is recommended.

    Q: What should I do if I am accused based on circumstantial evidence?

    A: Immediately seek legal counsel. A lawyer can assess the evidence against you, challenge weak inferences, and build a strong defense based on reasonable doubt and alternative explanations.

    ASG Law specializes in Criminal Litigation and Defense. Contact us or email hello@asglawpartners.com to schedule a consultation.